Key Findings
- Economic: Citigroup Global Markets Inc. repeatedly underwrote State of Israel sovereign debt, including participation in syndicates for aggregate offerings of $5 billion in February 2025 and $6 billion in January 2026, while Citibank, N.A. continued separate fiscal-agent and related securities-administration functions.1, 2, 3
- Political: Citibank, N.A.’s fiscal-agency relationship with the State of Israel dates to 2000 and remained documented through January 2026. Citi Foundation also made a $1 million grant to Leket Israel in October 2023 and later provided another $1 million divided between UNICEF and Save the Children for emergency assistance in affected areas.4, 5, 3
- Digital: Citi has maintained an Israel-linked technology and venture footprint, including an innovation lab, Tel Aviv venture activity and investments in companies including Silverfort, BioCatch and Capitolis, but the audits did not establish deployment of those technologies for Israeli military, intelligence, surveillance or sovereign-cloud purposes.6, 7, 8, 9, 10, 11
- Not found: No public evidence identified of a direct Citi defence-procurement contract with the Israeli Ministry of Defence or IDF, Citi manufacture or supply of weapons or military equipment, a qualifying military-support transaction, or a settlement-specific Citi branch, facility or service contract.12
Target Profile
| Field | Detail |
|---|---|
| Company Name | Citibank, N.A., reviewed within the Citigroup banking network; the audits also distinguish Citigroup Global Markets Inc. (CGMI) where it is the entity named in sovereign-debt transactions.13, 1 |
| Jurisdiction | Citigroup Inc. is a Delaware corporation; Citibank, N.A. is a United States national banking association.13 |
| Headquarters | No public evidence identified in the four audits establishing the global headquarters. |
| Sector | Banking, capital markets and financial services.13 |
| Ownership | Citibank, N.A. is described as wholly owned by Citigroup Inc.; Citigroup Inc. is the SEC-reporting public-company parent.13 |
| Key Executives / Governance | Jane Fraser is Chair and CEO of Citigroup; John Dugan is Lead Independent Director. The audits also identify Sunil Garg as CEO of Citibank, N.A.14, 15 |
| Israeli-Nexus Summary | A regulated Citibank branch in Tel Aviv, a longstanding State of Israel fiscal-agency relationship, repeated CGMI underwriting of Israeli sovereign debt, and a documented technology/venture presence in Israel.16, 17, 1, 2, 18 |
Key Facts:
- Bank of Israel lists Citibank N.A. as a supervised foreign bank, and historical Bank of Israel research states that its Israel branch began operating in 2000, initially serving large companies.16, 19
- Citi’s current Israel privacy statement identifies the operating entity as Citibank, N.A. acting through its Israel Branch in Tel Aviv.17
- The audits distinguish Citibank, N.A.’s fiscal-agent functions from CGMI’s underwriting roles and do not attribute one entity’s conduct automatically to another.1, 2, 3
Executive Summary
Citibank’s strongest documented Israel nexus is economic. Citibank, N.A. operates a regulated foreign-bank branch in Tel Aviv and has served as fiscal agent for State of Israel sovereign securities under an agreement dating to March 2000. Citigroup Global Markets Inc., a separate Citi entity, has repeatedly participated in Israeli sovereign-bond underwriting. Verified examples include a $2 billion issue in 2013, a $5 billion issue in 2020, a $2 billion issue in 2023, a $5 billion issue in February 2025 and a $6 billion issue in January 2026; these are aggregate offering amounts, not amounts solely financed by Citi.16, 17, 1, 2, 20, 21, 22 The March 2024 $8 billion issue is an important limiting fact: CGMI was not one of its named underwriters, although Citibank, N.A. continued to perform fiscal-agent, registrar, transfer-agent and paying-agent functions.23
The reviewed scoring record gives Economic the dossier’s governing score. The final V6.5 values are I=8.80, M=7.40 and P=9.00, producing Economic=8.80. The examiner-adjudicated rationale treats repeated direct underwriting of sovereign debt as high-impact economic activity and notes continuation after the July 2024 ICJ advisory opinion and November 2024 ICC warrants. The proximity score reflects the direct contractual role documented in State of Israel securities filings rather than an inferred exposure through third parties.1, 2
The political-domain record is narrower. Citibank’s continuing fiscal-agency arrangement directly serves the State of Israel’s sovereign-financing machinery, but the underlying conduct is commercial banking activity. The V6.5 adjudication therefore treats its pre-escalation character as business-as-usual state-facing activity rather than ideological advocacy, military donation or a non-commercial governmental partnership. Corporate communications in October 2023 included Jane Fraser’s condemnation of the Hamas attack, support for Citi personnel in Israel and a Citi Foundation grant to Leket Israel, followed by additional aid to UNICEF and Save the Children and broader statements concerning civilian suffering, antisemitism and Islamophobia.4, 5 The audits found no verified Citi lobbying position, PAC expenditure or corporate contribution specifically tied to Israel-Palestine policy, anti-BDS legislation, AIPAC, CFI or a comparable advocacy body.
The military and digital audits produced no qualifying V6.5 frame. The military audit found no public evidence of a Citi defence-procurement contract with the IDF or Israeli Ministry of Defence, weapon or component supply, export licensing, base services, military logistics or settlement military infrastructure. A 2024 UN Special Procedures communication alleged Citigroup investment exposure to defence companies supplying Israel, but expressly remained an allegation rather than an adjudicated finding; the available Boeing credit agreement does not tie Citi’s facility to an Israeli weapons shipment.12, 24 The digital audit documented an Israeli R&D and venture footprint but found no evidence of Citi providing cloud, AI, surveillance, offensive-cyber or other digital systems to Israeli military or intelligence bodies.6, 7
Under the fixed V6.5 scoring, Citibank/Citigroup receives a Complicity Index score of 758, placing it in Tier B (Severe Complicity). That result is driven overwhelmingly by the directly documented sovereign-financing relationship rather than by military or digital activity.
Timeline of Relevant Events
| Date | Event |
|---|---|
| 2000 | Citibank N.A.’s Israel branch began operating in Israel, initially serving large companies; the State of Israel and Citibank, N.A. also entered the fiscal-agency agreement later cited in subsequent sovereign-securities filings.19, 3 |
| 2013 | CGMI was named with Barclays Capital and Goldman Sachs as an underwriter of $2 billion in Israeli sovereign bonds; Citibank, N.A. was separately identified as fiscal agent.20 |
| 2014–2015 | Citi publicly described a Technology Innovation Lab in Israel and an accelerator linked to the local technology ecosystem.6, 25 |
| 31 Mar 2020 | CGMI participated in underwriting $5 billion of State of Israel bonds; Citibank, N.A. continued as fiscal agent.21 |
| 2020 | Citi participated in investment relationships with Silverfort and BioCatch, establishing Israeli-sector technology and innovation ties without establishing production deployment inside Citibank.8, 9 |
| Jan 2023 | CGMI participated in a $2 billion State of Israel sovereign issue while Citibank, N.A. was fiscal agent.22 |
| 10 Oct 2023 | Jane Fraser published “Support for Israel”; Citi Foundation announced $1 million for humanitarian organisations operating in Israel, later identified as Leket Israel.4, 5 |
| 22 Oct 2023 | Citi announced another $1 million divided between UNICEF and Save the Children and broadened its public framing to civilian suffering across the region.5 |
| 5 Mar 2024 | Israel issued $8 billion of bonds. CGMI was not a named underwriter; Citibank, N.A. remained registrar, fiscal agent, transfer agent and principal paying agent.23 |
| 20 May 2024 | UN Special Procedures sent Citigroup a communication concerning alleged investment exposure to defence companies supplying Israel; the communication was an allegation and request for information, not an adjudication.12 |
| 25 Nov 2024 | Citi participated in a strategic investment in Israeli fintech Capitolis, investing $5 million and obtaining board representation.10 |
| 11 Feb 2025 | CGMI was one of five underwriters for $5 billion of State of Israel bonds; Citibank, N.A. remained fiscal agent.1 |
| 6 Jan 2026 | CGMI was one of five underwriters for $6 billion of State of Israel bonds. A related prospectus allocated CGMI $1.2 billion across three maturities, while Citibank, N.A. remained registrar, fiscal agent, transfer agent and principal paying agent.2, 3 |
| 6 Oct 2026 | Citi led Capitolis’s $120 million Series E equity financing.11 |
Corporate Overview
The audits treat Citigroup Inc., Citibank, N.A. and Citigroup Global Markets Inc. as legally distinct entities. Citigroup Inc. is the SEC-reporting parent. Citibank, N.A. is its primary banking subsidiary and operates the regulated Israel branch. CGMI is separately named in State of Israel securities documents as an underwriter or book-running manager in specified sovereign offerings.13, 16, 1, 2
The Israeli operating footprint verified by the audits centres on Tel Aviv. Citibank, N.A. acts through its Israel Branch at 121 Menachem Begin Street, and Citi Ventures separately lists a Tel Aviv presence at the same address.17, 18 The audits found no verified Citi branch, office, acquired subsidiary or directly documented lending facility in an Israeli settlement in the West Bank, East Jerusalem or occupied Golan Heights. The most recent OHCHR settlement-business database was not successfully retrieved during the economic audit, so that finding is limited to the reviewed evidence rather than a categorical declaration of absence.
Citi has also maintained a documented technology and venture connection to Israel. Historical first-party material described a Technology Innovation Lab and accelerator, while later evidence described the Israel lab as working across data, AI, blockchain and cybersecurity. Current venture evidence includes a Tel Aviv Citi Ventures office and strategic investments in Israeli-sector firms including Silverfort, BioCatch and Capitolis.6, 7, 8, 9, 10, 11, 18 These relationships establish an innovation and investment footprint but do not by themselves establish production use of the companies’ products, customer-data hosting in Israel, or provision of technology to Israeli state-security bodies.
Domain Summaries
Military: Military
Mechanism of Involvement
The military audit produced no qualifying V6.5 frame. No public evidence was identified of a procurement contract between Citigroup, Citibank, N.A. or CGMI and the Israeli Ministry of Defence, IDF, Israel Prison Service or Border Police. The audit likewise found no Citi manufacture or supply of weapons, ammunition, military platforms, critical subsystems, tactical equipment, heavy machinery, military infrastructure, base services, freight services or military logistics.
The strongest adverse military-domain material was financial rather than military-operational. UN Special Procedures wrote to Citigroup in May 2024 concerning allegations that it continued investing in defence companies, including Boeing, associated with arms transfers to Israel.12 The audit treated this accurately as an allegation and request for information rather than a judicial, regulatory or factual determination.
Citibank, N.A. was also administrative agent and joint lead arranger/book manager on a 2021 Boeing revolving credit facility with $5.28 billion of commitments.24 The agreement does not identify an Israeli weapons purchase or shipment as the use of that facility. It therefore does not establish that Citi financed weapons supplied to Israel.
Counter-Arguments and Evidence Limits
Citi’s strongest defence is the absence of a directly documented qualifying military transaction. The reviewed record contains no Israeli defence-procurement contract, export licence, end-user certificate, military-base contract, weapons shipment, co-production programme or direct loan to a named Israeli defence prime.
Citi’s environmental and social framework also contains a Military Equipment policy restricting direct financing of specified weapons categories and subjecting other military-equipment finance to heightened review.26 That policy does not prove compliance in every case, but neither does it establish an Israel-specific military-finance transaction.
The UN communications document scrutiny, not adjudicated causation. The Boeing financing evidence is likewise insufficient to connect the facility to weapons delivered to Israel. Those evidentiary limits are why the final Military score remains zero.
Named Entities and Evidence Map
- Citigroup Inc. - recipient of the May 2024 UN Special Procedures communication.12
- Citibank, N.A. - banking entity; party to the Boeing credit facility as administrative agent and arranger, without a demonstrated Israel-specific weapons use.24
- Boeing - defence manufacturer referenced in the UN scrutiny and Citi credit relationship.12, 24
- Israeli Ministry of Defence / IDF - no public evidence identified of a direct Citi procurement contract.
Digital: Digital
Mechanism of Involvement
The digital audit likewise produced no mechanically eligible V6.5 frame. Citi’s digital nexus is a documented Israeli technology, R&D and venture-investment footprint rather than demonstrated state-security technology provision.
Citi publicly described an Israel Technology Innovation Lab in 2014, and a 2022 profile described the lab as a strategic technology hub working across data, AI, blockchain and cybersecurity.6, 7 Citi Ventures currently lists a Tel Aviv office.18
Verified commercial relationships include participation in Silverfort’s 2020 financing, with later evidence showing Citi Ventures remained an investor;27 a 2020 BioCatch investment that included representation on a Client Innovation Board; and strategic investments in Capitolis in 2024 and 2026.8, 9, 10, 11
Counter-Arguments and Evidence Limits
The audits found no public evidence that Citibank deployed Silverfort, BioCatch or another identified Israeli-origin product in its production environment. The BioCatch relationship establishes investment and innovation-board participation but not customer-authentication deployment. The Silverfort record establishes investment and accelerator ties but not enterprise licensing.
No public evidence was identified of Citi participating as a supplier in Project Nimbus or another Israeli sovereign-cloud programme. Nor was evidence found of Citi supplying AI, surveillance, computer-vision, offensive-cyber, autonomous-targeting or other digital systems to the Israeli military, intelligence services or law-enforcement bodies.
The Israel R&D footprint therefore remains relevant as an economic and technology-ecosystem relationship, but it does not meet the audited digital-domain threshold for a qualifying adverse frame.
Named Entities and Evidence Map
- Citi Technology Innovation Lab / Citi Israel Innovation Lab - historical Israeli financial-technology and R&D operation.6, 7
- Citi Ventures - current Tel Aviv venture presence.18
- Silverfort - investment and accelerator relationship; production deployment not established.8
- BioCatch - investment and Client Innovation Board relationship; Citibank deployment not established.9
- Capitolis - strategic Citi investment in 2024 and Citi-led financing in 2026.10, 11
- Israeli state, military and intelligence bodies - no public evidence identified of a qualifying Citi digital-technology contract.
Economic: Economic
Mechanism of Involvement
Economic involvement is the dossier’s strongest documented vector. Citibank, N.A. has operated in Israel since 2000 and remains a supervised foreign bank with a current Tel Aviv branch.16, 17, 19 Its relationship with the State of Israel extends directly into sovereign-finance infrastructure through the longstanding fiscal-agency agreement.3
CGMI has repeatedly acted as an underwriter of Israeli sovereign debt. The audits document involvement in issues of $2 billion in 2013, $5 billion in 2020, $2 billion in 2023, $5 billion in February 2025 and $6 billion in January 2026.1, 2, 20, 21, 22 The January 2026 prospectus further records CGMI as a joint book-running manager with $1.2 billion allocated across 2031, 2036 and 2056 bonds.3
The March 2024 transaction demonstrates why entity and transaction specificity matter. Israel issued $8 billion in bonds, but CGMI was not among the four named underwriters. Citibank, N.A. nevertheless remained involved as registrar, fiscal agent, transfer agent and principal paying agent.23
The final V6.5 economic score is I=8.80, M=7.40 and P=9.00. The adjudicated rationale treats direct sovereign underwriting as a high-impact activity and applies the minimum escalation associated with its continuation after the July 2024 ICJ advisory opinion and November 2024 ICC warrants. High proximity reflects direct contractual participation documented in sovereign filings.
Counter-Arguments and Evidence Limits
Citi can correctly argue that sovereign debt-market services are commercial banking and capital-markets activities and are not equivalent to a military-procurement contract. None of the cited bond documents assigns the proceeds of the particular Citi-underwritten offerings to a named weapons programme.
It is also important that Citi was not a named underwriter of the March 2024 $8 billion issue. Describing it as an underwriter of that transaction would be wrong; its role there was fiscal and securities administration.23
The economic audit found no public evidence of Citi sourcing settlement-origin goods, running physical retail supply chains from settlements, acquiring an Israeli operating company, or maintaining a verified branch or facility in a West Bank, East Jerusalem or Golan settlement. Israel-specific revenue, profit, tax and workforce figures were not established in the reviewed material.
These limits do not negate the sovereign-finance relationship, but they define its nature: direct banking and capital-markets services to the State of Israel rather than manufacturing, physical supply or settlement-based operations.
Named Entities and Evidence Map
- Citibank, N.A. Israel Branch - regulated Tel Aviv banking branch.16, 17
- Citigroup Global Markets Inc. - underwriter/book-running manager in specified Israeli sovereign issues.1, 2, 3
- State of Israel - sovereign issuer and counterparty to the fiscal-agency structure.
- Citibank, N.A. - fiscal agent, registrar, transfer agent and principal paying agent in the documented securities framework.23, 3
- Citi Ventures - Tel Aviv venture-investment presence.18
Political: Political
Mechanism of Involvement
The political score is driven primarily by Citibank’s direct state-facing fiscal-agency role rather than ideological advocacy. The fiscal-agency agreement dates to 13 March 2000 and remained cited in State of Israel securities filings through January 2026.3 The examiner-adjudicated V6.5 rationale characterises the underlying conduct as commercial state-facing activity and assigns a pre-escalation business-as-usual impact level, with continuation after the July and November 2024 legal milestones producing the final I=4.50.
Citi’s October 2023 communications form a separate political-context record. Jane Fraser condemned the Hamas attack, expressed support for Citi employees in Israel and announced a $1 million Citi Foundation humanitarian grant that was subsequently identified as going to Leket Israel.4, 5 A later communication announced another $1 million divided between UNICEF and Save the Children and addressed civilian suffering across the region, antisemitism, Islamophobia and hatred.5
The audits found general Citi lobbying and PAC infrastructure but no public evidence tying a Citi lobbying position, PAC expenditure or corporate contribution specifically to Israel-Palestine policy, anti-BDS legislation, AIPAC, CFI or a comparable regional advocacy organisation.
Counter-Arguments and Evidence Limits
Citi’s strongest defence is that the fiscal-agency relationship is a commercial financial-service arrangement rather than an ideological, diplomatic or military alliance. The audits identified no non-commercial state propaganda partnership, state ownership, golden share, charter requirement advancing Israeli geopolitical objectives, or founding mission tied to Israel.
The Foundation’s first October 2023 grant went to Leket Israel, while the subsequent $1 million was split between UNICEF and Save the Children for emergency assistance in affected areas.4, 5 No public evidence was identified of a Citi, Citibank or Citi Foundation donation to the IDF, FIDF, JNF/KKL, a settlement body or military-welfare organisation.
The settlement check also remains bounded by incomplete database retrieval. No settlement-specific Citi location or service contract was verified, but the audit does not convert an incomplete retrieval into categorical proof of absence.
Named Entities and Evidence Map
- State of Israel - counterparty to the fiscal-agency and sovereign-securities relationships.3
- Citibank, N.A. - fiscal agent and securities-administration provider.23, 3
- Citigroup Global Markets Inc. - sovereign-bond underwriter in the separately scored economic record.1, 2
- Jane Fraser - Citigroup Chair and CEO; author of the October 2023 corporate statements.14, 4, 5
- Citi Foundation - provided the documented humanitarian grants.4, 5
- Leket Israel, UNICEF and Save the Children - recipients identified in the corporate grant disclosures.5
Complicity Index Score
Method: V6.5
| Domain | I | M | P | V-Domain Score |
|---|---|---|---|---|
| Military | 0.00 | 0.00 | 0.00 | 0.00 |
| Digital | 0.00 | 0.00 | 0.00 | 0.00 |
| Economic | 8.80 | 7.40 | 9.00 | 8.80 |
| Political | 4.50 | 8.50 | 9.20 | 4.50 |
- V_MAX: 8.80 Avg_OTHERS: 1.50
- Complicity Index score: 758 Tier: B (Severe Complicity)
V_MAX is driven by the economic domain because the reviewed record directly documents repeated CGMI underwriting of State of Israel sovereign debt and Citibank, N.A.’s continuing fiscal-agency role. The political score reflects the same state-facing fiscal relationship at a lower impact classification, while military and digital remain zero because the audits found no qualifying frame.
The method is scale-free, evidence-only and human-vetted: Impact reflects the type of activity, Magnitude its scale and Proximity the directness of the documented relationship.
Methodology Note
- Evidence is limited to the four completed domain audits and the fixed V6.5 scoring record. Claims marked unresolved, unverified or incomplete in those audits are either carried with those caveats or omitted.
- Impact (I) measures the character of the documented activity; Magnitude (M) measures its scale; Proximity (P) measures how directly the target entity is connected to the act.
- Temporal treatment is evidence-sensitive: historical or exited activities are not treated as current without evidence of continuation, while continuing post-2024 activity is assessed according to the V6.5 temporal rules.
- Entity attribution is non-transitive. Citigroup Inc., Citibank, N.A., Citibank’s Israel Branch and CGMI are treated separately where source documents identify different legal entities.
- Settlement operation, if directly verified, can bear on both Economic and Political, but no verified settlement-specific Citi operation was established in these audits.
- “No public evidence identified” means the reviewed checks did not establish the claimed relationship; it is not converted into proof that no evidence could exist outside the reviewed record.
Footnotes
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https://www.sec.gov/Archives/edgar/data/52749/000110465925015165/tm256980d1_ex99-l.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11
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https://www.sec.gov/Archives/edgar/data/52749/000110465926003199/tm263022d1_ex99-k.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10
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https://www.sec.gov/Archives/edgar/data/52749/000110465926001036/tm2534616-2_424b5.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12
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https://www.citigroup.com/global/news/perspectives/2023/support-for-israel ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7
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https://www.citigroup.com/global/news/perspectives/2023/one-firm-one-community ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10
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https://www.citigroup.com/global/news/perspectives/2014/accelerating-technology-innovation ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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https://www.calcalistech.com/ctech/articles/0,7340,L-3926316,00.html ↩ ↩2 ↩3 ↩4 ↩5
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https://www.silverfort.com/press-news/news/silverfort-secures-30-million-in-series-b-funding/ ↩ ↩2 ↩3 ↩4 ↩5
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https://www.biocatch.com/press-release/major-global-banks-invest-20-million-in-biocatch-and-join-american-express-ventures-on-new-client-innovation-board ↩ ↩2 ↩3 ↩4 ↩5
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https://capitolis.com/capitolis-announces-new-strategic-investments-from-citi-morgan-stanley-state-street-and-ubs/ ↩ ↩2 ↩3 ↩4 ↩5
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https://capitolis.com/capitolis-announces-220-million-in-financing-including-120-million-series-e-at-1-9-billion-valuation-from-bank-of-america-barclays-bnp-paribas-citi-j-p-morgan-nomura-state-street-ubs-tra/ ↩ ↩2 ↩3 ↩4 ↩5
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https://spcommreports.ohchr.org/TMResultsBase/DownLoadPublicCommunicationFile?gId=29094 ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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https://www.sec.gov/Archives/edgar/data/831001/000083100126000011/c-20251231.htm ↩ ↩2 ↩3 ↩4 ↩5
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https://www.sec.gov/Archives/edgar/data/831001/000120677426000185/citi4583461-def14a.htm ↩ ↩2
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https://www.citigroup.com/global/about-us/leadership/sunil-garg-2 ↩
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https://kamakama.gov.il/en/economic-roles/supervision-and-regulation/list_supervised/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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https://www.citigroup.com/tts/sa/tts-privacy-statements/assets/docs/israel-privacy.pdf ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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https://www.citigroup.com/ventures/contact-us.html ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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https://kamakama.gov.il/en/economic-roles/research-and-publications/all-research/research-papers/foreign-banks-activity-in-israel/ ↩ ↩2 ↩3
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https://www.sec.gov/Archives/edgar/data/52749/000114420413004972/v333401_ex99-g.htm ↩ ↩2 ↩3
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https://www.sec.gov/Archives/edgar/data/52749/000110465920042989/tm2014106d4_exj-1.htm ↩ ↩2 ↩3
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https://www.sec.gov/Archives/edgar/data/52749/000110465923004047/tm2233139-5_exhibith.htm ↩ ↩2 ↩3
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https://www.sec.gov/Archives/edgar/data/52749/000110465924031445/tm247783-2_424b5.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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https://www.sec.gov/Archives/edgar/data/12927/000119312521089532/d149318dex101.htm ↩ ↩2 ↩3 ↩4
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https://www.citigroup.com/global/news/perspectives/2015/citi-innovation-lab-spotlight ↩
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https://www.citigroup.com/rcs/citigpa/storage/public/environmental-and-social-policy-framework.pdf ↩
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https://www.silverfort.com/press-news/press/silverfort-raises-116m-to-deliver-a-unified-layer-of-identity-security-across-all-enterprise-resources/ ↩
